KeshrichandJaisukhlal v. CIT

199 ITR 702High Court1993#1848 most cited

What is KeshrichandJaisukhlal v. CIT authority for?

Notional income, such as notional interest on interest-free loans, cannot be brought to tax without a specific statutory provision in the Income Tax Act. Only real income that has accrued or been received by the assessee is subject to income tax.

62

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2024.

Also referred to as

Keshrichand Jaisukhlal v. CIT · Highways Construction Co. Pvt. Ltd. v. CIT · 199 ITR 702 · notional income · notional interest · interest-free loans · real income · taxability · section 36(1)(iii) · section 28(iv) · commercial expediency · Gauhati High Court

Sections most often in play

Section 142(1)Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 36(1)(iii)Section 37

Issues it is cited on

section 28(iv)surrender of incomeright to receivemercantile system of accountingloose paperssection 36(1)(iii)commercial expediencysection 28section 234apenalty u/s 271(1)(c)section 133asection 131

Judgments citing KeshrichandJaisukhlal v. CIT

BIOCON BIOLOGICS LIMITED,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), BANGALORE

ITA 1590/BANG/2024[2020-21]Status: DisposedITAT Bangalore23 Dec 2024AY 2020-21

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadavit(Tp)A No.1590/Bang/2024

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 143(3)Section 92Section 92C

…he Act, off Course considering special effects of COVID -19. 18. Regarding the recharacterisation of the transaction by the learned TPO, the learned authorized representative has placed reliance on the decision of the honourable Guwahati High Court in case of 199 ITR 702 in case of Highway construction company private limited. We have carefully considered that decision and find that it is not related to the transfer pricing issues. Here the learned transfer pricing officer has also not recharacterised the transaction but has merely applied the law and benchmarked the arm's-length price of the international transa…

SIMOCO SYSTEMS AND INFRASTRUCTURE SOLUTIONS LIMITED,KOLKATA vs. ITO WARD 2 (1), KOLKATA

In the result, the appeal filed by the assessee is allowed

ITA 123/KOL/2024[2018-19]Status: DisposedITAT Kolkata29 Nov 2024AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Year: 2018-19

For Appellant: Indranil Banerjee, ARFor Respondent: Ankur Goyal, JCIT, Sr. DR
Section 115JSection 133(6)Section 143(3)Section 144BSection 250

…s purposes as the assessee had a project under construction named as “SANHITA”. Reliance was also placed on several other judicial pronouncements, the relevant extracts of the findings of which are as under: 1. Highways Construction Co. Pvt. Ltd. v CTT [1993] 199 ITR 702 (Gauhati HC): "There is no finding of fact to the effect that actually the loan had been granted to the managing director or any other person on interest, or that interest had actually been collected and the collection of the interest was not reflected in the accounts. The finding of the Income Tax Officer is that the assessee ought to have 13 S…

ACIT, CENTRAL CIRCLE- 26 , NEW DELHI vs. KRISHAN KUMAR MODI, NEW DELHI

The Appeal of the Revenue is dismissed

ITA 4554/DEL/2018[2014-15]Status: DisposedITAT Delhi06 Nov 2024AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 4554/Del/2018, (A.Y.2014-15)

Section 132Section 143(3)

…within the terms of funds/loan advanced. • CIT vs. Goyal M.G. Gases (P) Ltd.: 303 ITR 159 (Del.) • B & A Plantations and Industries vs. CIT: 242 ITR 22 (Gau.) • KeshrichandJaisukhlal vs. CIT: 248 ITR 47 (Gau.) • Highways Construction Co. Pvt. Ltd vs. CIT: 199 ITR 702 (Gau.) • Jwala Prasad Radha Krishna vs. CIT [1992]: 198 ITR 415(All) • CIT vs. Punjab Financial Corpn. Ltd.: 295 ITR 510 (P&H HC) • CIT vs. South India Corpn. (Agencies) Ltd.: 293 ITR 237 (Chennai HC) • CIT vs. Sanghi Finance and Investment Ltd.: 190 CTR 207 (MP) 6.4 We have considered rival submissions and the decisions relied upon by both t…

ACIT, CENTRAL CRCLE-18, NEW DELHI vs. SHIMMER DEVELOPERS P.LTD, NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 1497/DEL/2018[2011-12]Status: DisposedITAT Delhi21 Oct 2024AY 2011-12

Bench: Pradip Kumar Kedia & Shri Anubhav Sharma

Section 132Section 143(3)Section 147Section 150Section 68

…rest free loans is not taxable in the absence of specific provision in the ITA 5.2 A similar question of taxation of notional income from interest free loans given by the company to its managing director arose in Highiways Constructions Co. Pvt. Ltd. v. CIT, (199 ITR 702 (Gauhaii). The Gauhati High Court did not uphold the taxation of notional income, noting that, if the assessee had not bargained for interest, or had not. collected interest, we fail to see how the Income Tax authorities can fix a notional interest as due, or collected by the assessee ". Therefore, the judicial approach does not support taxation…

TEAM GLOBAL LOGISTICS PVT. LTD.,MUMBAI vs. DCIT-11(3)(1), MUMBAI

In the result the appeal is allowed

ITA 4453/MUM/2023[2012-13]Status: DisposedITAT Mumbai15 Oct 2024AY 2012-13

Bench: SHRI BR BASKARAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 143(2)Section 143(3)Section 147Section 148Section 151(1)Section 250Section 68

…show that the alleged interest was not reflected in the accounts. The only finding recorded was that the assessee "ought to have charged interest. Referring to an earlier decision of the Guwahati High Court, in Highways Construction Co. (P) Ltd. v. CIT [1993] 199 ITR 702, the Court observed that their attention had not been invited to any provision of the Income-Tax Act empowering the income- tax authorities to include in the income, interest which was not due or not collected. 6. In similar vein, when we asked Mr Sahni, who is appearing for the respondent to point out some provision of the Income Tax Act, whereu…

ITO, WARD-2(4), NEW DELHI vs. ANTHEIA CONSTRUCTIONS P.LTD, NEW DELHI

In the result, both the appeals filed by the Revenue are dismissed

ITA 4963/DEL/2017[2014-15]Status: DisposedITAT Delhi13 Sept 2024AY 2014-15

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahman

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR
Section 133Section 142(1)Section 143(2)

…ding of the Tribunal in paragraph 11 of its order, in our view, cannot be faulted. It relied on a decision of a co-ordinate bench of the Tribunal in another matter where a decision of the Gauhati High Court in Highways Construction Co. (P.) Ltd. v. CIT (1993] 199 ITR 702 was considered. The finding there was that only the real income earned by the assessee could be brought to tax, not some notional income. The question suggested as a substantial of law seems to proceed on a basis that some notional interest might have been asked to be assessed. We are unable to agree." f. The Hon'ble High Court of Punjab and Hary…

ITO, NEW DELHI vs. M/S ANTHEIA CONSTRUCTIONS PVT. LTD.,, NEW DELHI

In the result, both the appeals filed by the Revenue are dismissed

ITA 2373/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Sept 2024AY 2013-14

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahman

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR
Section 133Section 142(1)Section 143(2)

…ding of the Tribunal in paragraph 11 of its order, in our view, cannot be faulted. It relied on a decision of a co-ordinate bench of the Tribunal in another matter where a decision of the Gauhati High Court in Highways Construction Co. (P.) Ltd. v. CIT (1993] 199 ITR 702 was considered. The finding there was that only the real income earned by the assessee could be brought to tax, not some notional income. The question suggested as a substantial of law seems to proceed on a basis that some notional interest might have been asked to be assessed. We are unable to agree." f. The Hon'ble High Court of Punjab and Hary…

SAHARA INFRASTRUCTURE & HOUSING LIMITED,KOLKATA vs. ACIT CENTRAL CIRCLE-1, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 1726/DEL/2020[2017-18]Status: DisposedITAT Delhi02 Nov 2023AY 2017-18

Bench: Shri M. Balaganesh & Shri Anubhav Sharmasahara Infrastructure & Vs. Acit, Housing Ltd, Central Circle-1, Sahara India Sadan, 2A, New Delhi Shakespeare Sarani, Kolkata-700071 (Appellant) (Respondent) Pan: Aabcg2655B Assessee By : Sh. Dinesh Verma, Adv Shri Hardeep Singh, Ca Revenue By: Shri Kanv Bali, Sr. Dr Date Of Hearing 30/10/2023 Date Of Pronouncement 02/11/2023

For Appellant: Sh. Dinesh Verma, AdvFor Respondent: Shri Kanv Bali, Sr. DR
Section 139(4)Section 143(3)

…fortified by the decision of Hon’ble Allahabad High Court in the case of Jwala Prasad Radha Krishna vs CIT reported in 198 ITR 415 (All) and also on the decision of Hon’ble Gauhati High Court in the case of Highways Construction Co. Pvt Ltd vs CIT reported in 199 ITR 702 (Gau). Sahara Infrastructure & Housing Ltd 4. In view of the aforesaid observations and respectfully following the judicial precedents relied upon hereinabove, we hold that the addition made towards notional interest in the sum of Rs 7,20,000/- deserves to be deleted. Accordingly, the grounds raised by the assessee are allowed. 5. In the result…

SHRI SHYAMSUNDAR SONI KARTA HUF,BIKANER vs. ACIT, CIRCLE,, BIKANER

In the results the appeal filed by the

ITA 67/JODH/2023[2019-20]Status: DisposedITAT Jodhpur07 Aug 2023AY 2019-20

Bench: Its Hearing Before Your Honours.”

Section 115BSection 131Section 133ASection 139(1)Section 147Section 148Section 234A

…s required to be made in the addition made by the assessing officer with regard to interest on cash loans of Rs. 90000/- during the year. The appellant has claimed that its facts are identical to the case of Highway Construction Company Pvt Ltd Vs CIT (1993) 199 ITR 702. However, in the para reproduced in the reply itself it is found in that case that there was no finding of fact that loan was granted on interest. The finding of the Income-Tax officer is that the assessee could have collected interest. Facts of the present case are entirely different. Here, interest is charged by the appellant as per impounded d…

SHRI SHYAMSUNDAR SONI KARTA HUF,BIKANER vs. ACIT, CIRCLE,, BIKANER

In the results the appeal filed by the

ITA 66/JODH/2023[2018-19]Status: DisposedITAT Jodhpur07 Aug 2023AY 2018-19

Bench: Its Hearing Before Your Honours.”

Section 115BSection 131Section 133ASection 139(1)Section 147Section 148Section 234A

…s required to be made in the addition made by the assessing officer with regard to interest on cash loans of Rs. 90000/- during the year. The appellant has claimed that its facts are identical to the case of Highway Construction Company Pvt Ltd Vs CIT (1993) 199 ITR 702. However, in the para reproduced in the reply itself it is found in that case that there was no finding of fact that loan was granted on interest. The finding of the Income-Tax officer is that the assessee could have collected interest. Facts of the present case are entirely different. Here, interest is charged by the appellant as per impounded d…

SHRI SHYAMSUNDAR SONI KARTA HUF,BIKANER vs. ACIT, CIRCLE,, BIKANER

In the results the appeal filed by the

ITA 65/JODH/2023[2017-18]Status: DisposedITAT Jodhpur07 Aug 2023AY 2017-18

Bench: Its Hearing Before Your Honours.”

Section 115BSection 131Section 133ASection 139(1)Section 147Section 148Section 234A

…s required to be made in the addition made by the assessing officer with regard to interest on cash loans of Rs. 90000/- during the year. The appellant has claimed that its facts are identical to the case of Highway Construction Company Pvt Ltd Vs CIT (1993) 199 ITR 702. However, in the para reproduced in the reply itself it is found in that case that there was no finding of fact that loan was granted on interest. The finding of the Income-Tax officer is that the assessee could have collected interest. Facts of the present case are entirely different. Here, interest is charged by the appellant as per impounded d…

SHRI SHYAMSUNDAR SONI KARTA HUF,BIKANER vs. ACIT, CIRCLE,, BIKANER

In the results the appeal filed by the

ITA 64/JODH/2023[2016-17]Status: DisposedITAT Jodhpur07 Aug 2023AY 2016-17

Bench: Its Hearing Before Your Honours.”

Section 115BSection 131Section 133ASection 139(1)Section 147Section 148Section 234A

…s required to be made in the addition made by the assessing officer with regard to interest on cash loans of Rs. 90000/- during the year. The appellant has claimed that its facts are identical to the case of Highway Construction Company Pvt Ltd Vs CIT (1993) 199 ITR 702. However, in the para reproduced in the reply itself it is found in that case that there was no finding of fact that loan was granted on interest. The finding of the Income-Tax officer is that the assessee could have collected interest. Facts of the present case are entirely different. Here, interest is charged by the appellant as per impounded d…

SHRI SHYAMSUNDAR SONI KARTA HUF,BIKANER vs. ACIT, CIRCLE,, BIKANER

In the results the appeal filed by the

ITA 63/JODH/2023[2015-16]Status: DisposedITAT Jodhpur07 Aug 2023AY 2015-16

Bench: Its Hearing Before Your Honours.”

Section 115BSection 131Section 133ASection 139(1)Section 147Section 148Section 234A

…s required to be made in the addition made by the assessing officer with regard to interest on cash loans of Rs. 90000/- during the year. The appellant has claimed that its facts are identical to the case of Highway Construction Company Pvt Ltd Vs CIT (1993) 199 ITR 702. However, in the para reproduced in the reply itself it is found in that case that there was no finding of fact that loan was granted on interest. The finding of the Income-Tax officer is that the assessee could have collected interest. Facts of the present case are entirely different. Here, interest is charged by the appellant as per impounded d…

SHRI SHYAMSUNDAR SONI KARTA HUF,BIKANER vs. ACIT, CIRCLE,, BIKANER

In the results the appeal filed by the

ITA 62/JODH/2023[2014-15]Status: DisposedITAT Jodhpur07 Aug 2023AY 2014-15

Bench: Its Hearing Before Your Honours.”

Section 115BSection 131Section 133ASection 139(1)Section 147Section 148Section 234A

…s required to be made in the addition made by the assessing officer with regard to interest on cash loans of Rs. 90000/- during the year. The appellant has claimed that its facts are identical to the case of Highway Construction Company Pvt Ltd Vs CIT (1993) 199 ITR 702. However, in the para reproduced in the reply itself it is found in that case that there was no finding of fact that loan was granted on interest. The finding of the Income-Tax officer is that the assessee could have collected interest. Facts of the present case are entirely different. Here, interest is charged by the appellant as per impounded d…

SHRI SHYAMSUNDAR SONI KARTA HUF,BIKANER vs. ACIT, CIRCLE,, BIKANER

In the results the appeal filed by the

ITA 61/JODH/2023[2013-14]Status: DisposedITAT Jodhpur07 Aug 2023AY 2013-14

Bench: Its Hearing Before Your Honours.”

Section 115BSection 131Section 133ASection 139(1)Section 147Section 148Section 234A

…s required to be made in the addition made by the assessing officer with regard to interest on cash loans of Rs. 90000/- during the year. The appellant has claimed that its facts are identical to the case of Highway Construction Company Pvt Ltd Vs CIT (1993) 199 ITR 702. However, in the para reproduced in the reply itself it is found in that case that there was no finding of fact that loan was granted on interest. The finding of the Income-Tax officer is that the assessee could have collected interest. Facts of the present case are entirely different. Here, interest is charged by the appellant as per impounded d…

GUARDIAN NUTRITION & HEALTH SUPPLEMENTS PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE- 10(2), NEW DELHI

Appeal of the assessee is dismissed

ITA 6738/DEL/2017[2012-13]Status: DisposedITAT Delhi21 Nov 2022AY 2012-13

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat[Assessment Year: 2012-13

Section 143(3)Section 36(1)(iii)Section 40

…ering the disallowance are that (i) notional addition for non charge of interest has been disapproved in cases like Shivnandan Buildcon (P.) Ltd. [ 2015 ] 60 taxmann.com 347 (Delhi) and Guwahati High Court, in Highways Construction Co. (P.) Ltd. v. CIT [1993] 199 ITR 702, (relied on by the AR ) on the reasoning that any provision of the Income-Tax Act empowering the income-tax authorities to include in the income on notional basis, interest which was not due or not collected. (NB:In our case, the issue of course is not interest that is not allowable u/s 36(l)(iii) when interest bearing advances have been extended…

MODERN AUTOTRONIX,NEW DELHI vs. JT. CIT RANGE-18, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 3974/DEL/2019[2014-15]Status: DisposedITAT Delhi29 Dec 2021AY 2014-15

Bench: Ms. Suchitra Kambledr. B. R. R. Kumar(Through Video Conferencing) Ita No. 3974/Del/2019 : Asstt. Year : 2014-15 M/S Modern Autotronix, Vs Jcit, B-11, Diwan Shree Apartment, Range-18, 30, Firozshah Road, New Delhi-110002 New Delhi-110001 (Appellant) (Respondent) Pan No. Aarfm8678B

For Appellant: Sh. A. K. Srivastava, CAFor Respondent: Sh. Birender Singh, Sr. DR

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI Before Ms. Suchitra Kamble, Judicial Member Dr. B. R. R. Kumar, Accountant Member (Through Video Conferencing) ITA No. 3974/Del/2019 : Asstt. Year : 2014-15 M/s Modern Autotronix, Vs JCIT, B-11, Diwan Shree Apartment, Range-18, 30, Firozshah Road, New Delhi-110002 New Delhi-110001 (APPELLANT) (RESPONDENT) PAN No. AARFM8678B Assessee by : Sh. A. K. Srivastava, CA Revenue by : Sh. Birender Singh, Sr. DR Date of Hearing: 29.09.2021 Date of Pronouncement: 29.12.2021 ORDER Per Dr. B. R. R. Kumar, Accountant Member: Heard the arguments of both the pa…

SRINATH AGENCIES,,SECUNDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-10(1), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2238/HYD/2018[2014-15]Status: DisposedITAT Hyderabad03 Sept 2021AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2014-15 M/S. Srinath Agencies, Vs. Dy. Commissioner Of Secunderabad. Income Tax, Pan Aaqfs 3447M Circle 10(1), Hyderabad. (Appellant) (Respondent) Assessee By: Shri Siddharth Toshnival. Revenue By: Shri Rohit Majumdar (D.R)

For Appellant: Shri Siddharth ToshnivalFor Respondent: Shri Rohit Majumdar (D.R)
Section 133(6)Section 40A(2)

…ted that there was a commercial expediency in regard to the loan given to two persons as mentioned above. It is immaterial as to whether the project was not come into existence or not. He relied on the case law Highways Construction Co. P. Ltd. Vs. CIT (1993) 199 ITR 702 (Gau). He further submitted that the Assessing Officer cannot calculate the notional interest on the interest free advance given to two persons amounting to Rs.90 lakhs. Further in respect of commission payment, he stated that the TDS has been deducted on payments made to them at the applicable rates and the payments have been made through bankin…

SH. HANUMAN PRASAD GOYAL,BIKANER vs. ITO, SURATGARH

In the result, this appeal of the assessee stands allowed

ITA 151/JODH/2017[2013-14]Status: DisposedITAT Jodhpur02 Sept 2021AY 2013-14

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavhanuman Prasad Goyal, Vs. I.T.O. Prop.-Goyal Enterprises, Ward-Suratgarh. Dhan Mandi, Gharsana. Pan No. Abvpg 7484 Q Assessee By Shri Virendra Jain, Adv. Revenue By Miss. Kajal Singh, Jcit-Dr Date Of Hearing 12/08/2021 Date Of Pronouncement 06/09/2021 O R D E R Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Ld. Cit(A), Bikaner Dated 30/12/2016 For The A.Y. 2013-14, Wherein Following Grounds Have Been Taken By The Assessee: “1. On The Facts & Circumstances Of The Case, Ld. Cit(A) Has Erred In Confirming The Disallowance Made By A.O. On Account Of Interest Paid To Creditors Rs. 8,89,780/-. It Was Having No Force Or Solid Base Hence It Should Be Deleted. 2. On The Facts & Circumstances Of The Case, Ld. Ao Has Erred In Charging Interest U/S 234B & 234C Of The It Act, 1961. 3. The Appellant May Please Be Permitted To Raise Any Additional Or Alternative Grounds At Or Before Hearing.” 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

For Appellant: “1. On the facts and circumstances of the case
Section 143(3)Section 234BSection 402

…harging the interest. He was free to make summons to the parties of the appellant. The appellant has not received any amount yet up to today. He relied upon the decision of Hon'ble Supreme courts in the case of Highways Construction Co. Pvt. Ltd. v CIT [1993] 199 ITR 702, wherein this court held (page 708) : He also relied upon the following decision of Hon’ble High Court Delhi in the case of M/S SHIVNANDAN BUILDCON PVT. LTD Vs. THE COMMISSIONER OF INCOME TAX & ANR. Wherein this order it was held that the addition on account of a notional income on advances is deleted. 4 ITA 151/Jodh/2017 Hanuman Prasad Goyal V…

DCIT, NEW DELHI vs. M/S. ET INFRA DEVELOPERS PVT. LTD., NEW DELHI

In the result, appeal filed by the Revenue is dismissed and the Cross Objection filed by the assessee is partly allowed

ITA 3563/DEL/2016[2011-12]Status: DisposedITAT Delhi28 Jul 2021AY 2011-12

Bench: Shri R.K. Panda & Ms. Suchitra Kamble[Assessment Year: 2011-12] Dy. Commissioner Of Income M/S Et Infra Developers Pvt. Tax, Ltd. Central Circle-28, Room E-9, Panchsheel Park, No.317, Ara Centre, New Delhi-110017 Jhandewalan, New Delhi-110055 Pan-Aacce3646D Revenue Assessee Cross Objection No.277/Del/2016 (Arising Out Of Ita No.3563/Del/2016) [Assessment Year: 2011-12] M/S Et Infra Developers Pvt. Dy. Commissioner Of Income Ltd. Tax, E-9, Panchsheel Park, Central Circle-28, Room New Delhi-110017 No.317, Ara Centre, Jhandewalan, New Delhi-110055 Pan-Aacce3646D Assessee Revenue Revenue By Sh. Satpal Gulati Cit-Dr Assessee By Sh. M.P. Rastogi, Advocate

Section 132Section 153A

…only has to be assessed to tax and not the hypothetical income even though an entry has been made in the books of account. 25.2 Referring to the decision of the Hon’ble Guwahati High Court in the case of Highway Construction Co. Pvt. Ltd. vs CIT reported in 199 ITR 702 (Guwahati), he submitted that the Hon’ble High Court has held in the said decision that no CO.277/Del/2016 notional income in the form of interest can be assessed to tax because charging of interest from any party is the discretion of the assessee and the Act cannot compel an assessee to charge the interest. However, where the assessee has utiliz…

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